231 Model

A Corporate Governance tool

The Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 (the “231 Model”) is a tool that enables companies (legal entities) to prevent administrative liability arising from predicate offenses committed by individuals (senior management or employees under the direction of others) in the interest or for the benefit of the company itself.

The benefits for the company

Adopting and effectively implementing a 231 Model means:

• Establishing structured procedures, protocols, and controls to prevent the risk of committing predicate offenses.
• Demonstrating a strong commitment to regulatory compliance, thus reinforcing trust among all stakeholders (shareholders, employees, customers, suppliers, regulatory bodies, etc.).
• Increasing the company’s legal rating score, gaining competitive advantages in both public and private sector tenders.

Our 231 Model methodology

Since 2008, we have been designing, documenting, and implementing 231 Models, with a strong focus on improving corporate governance, strengthening ethical culture among personnel, and enhancing the company’s competitiveness in the market.
Our activities result in the creation of the following documents (components of the 231 Model):

• Risk Assessment
• Risk Prevention Protocols for the commission of predicate offenses under Legislative Decree 231/2001
• Code of Conduct for the Prevention of Predicate Offenses under Legislative Decree 231/2001
• Disciplinary System
• Statute of the Supervisory Body (OdV)
• Information Flows
• General Section of the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001

We design the 231 Model not only with the aim of preventing predicate offenses, but with a broader vision of overall organizational consistency.
We align the concept of the Model’s adequacy both as a reasonable corporate governance tool and as a reference point to demonstrate the company’s unintentional exposure to the risk of committing predicate offenses in judicial proceedings.

Our tailored services

Since 2008, we have also been providing the following services:

Periodic update of the 231 Model
We assist you in reviewing and updating the 231 Model to account for the revision and/or introduction of new predicate offenses and for organizational improvements following the identification of risk situations.

Training for senior management and employees
We design and deliver customized training programs tailored to your company’s specific needs to promote and strengthen a culture of compliance with laws, the Code of Ethics, and the Codes of Conduct issued by the company’s management body.

Supervisory Body (OdV) Membership
Our specialized professionals can serve as members of the Supervisory Body (either as a sole member or within a collegial body).

Internal auditing
Our internal audit service assesses the effectiveness of the 231 Model over time, ensures that procedures are followed and consistent with current regulations, and identifies critical issues and necessary improvements.